T-18 Changes: Medicare Bad Debt

Transmittal 18 Changes to Medicare Bad Debt include the following:

A. Changes to Medicare Bad Debt Schedules and Reporting

Exhibit 2A Medicare Bad Debt Template 

CMS finalized and released the required template hospitals must use to report their Medicare Bad Debt. The previous exhibit (Exhibit 2) instructed hospitals to complete 10 columns, the new exhibit (Exhibit 2A) includes 24 columns to be populated when preparing the Medicare Bad Debt patient listing. Notably, Exhibit 2A requires: 

• A separate exhibit is required for bad debt resulting in inpatient and outpatient services. 

• A separate exhibit is required for each CCN. 

Toyon’s take

The issuance of Exhibit 2A does not impact or change the policies and guidelines that hospitals must follow in order to compliantly claim Medicare Bad Debt under 42 CFR 413.89. The expectation is all hospitals will report and file their Medicare Bad Debt patient listings in a standard format. Hospitals must submit Exhibit 2A with the Medicare cost report. 

For further information, please contact Dylan Chinea at (925) 685-9312 or dylan.chinea@toyonassociates.com.